No. ______, Original In the Supreme Court of the United States STATE OF TEXAS, PLAINTIFF v. STATE OF CALIFORNIA MOTION FOR LEAVE TO FILE A BILL OF COMPLAINT, BILL OF COMPLAINT, BRIEF IN SUPPORT KEN PAXTON KYLE D. HAWKINS Attorney General of Texas Solicitor General Counsel of Record JEFFREY C. MATEER First Assistant Attorney MATTHEW H. FREDERICK General Deputy Solicitor General JASON R. LAFOND Assistant Solicitor General TREVOR W. EZELL Assistant Attorney General OFFICE OF THE ATTORNEY GENERAL P.O. Box 12548 (MC 059) Austin, Texas 78711-2548
[email protected] (512) 936-1700 TABLE OF CONTENTS 1. Motion for Leave to File a Bill of Complaint 2. Bill of Complaint 3. Brief in Support of Motion for Leave to File a Bill of Complaint 4. Appendix Selected Provisions of Texas Human Resources Code ........................................................ A.1 A.B. 1887 .................................................................... A.6 California Assembly Committee on the Judiciary, Analysis of A.B. 1887 (Mar. 12, 2016) ................... A.10 California Assembly Committee on the Judiciary, Analysis of A.B. 1887 (Apr. 1, 2016) ..................... A.25 Transcript Excerpts from March 15, 2016, Hearing on A.B. 1887 Before the California Assembly Committee on the Judiciary ............... A.41 (i) No. ______, Original In the Supreme Court of the United States STATE OF TEXAS, PLAINTIFF v. STATE OF CALIFORNIA MOTION FOR LEAVE TO FILE A BILL OF COMPLAINT The State of Texas moves the Court for leave to file the accompanying Bill of Complaint. In support of its motion, the State asserts that its claims arise under the United States Constitution; its claims are serious and dignified; and there is no alternative forum to provide adequate relief.